The end of the calendar year 2024 will be marked by a wave of legislative changes and law adjustments, especially in the form of complex approvals of several tax laws that have an impact on the already set business environment rules.
We therefore bring you an overview of the changes to several laws passed at the end of November 2024 that were not included in the consolidation package and enter into force in the first half of 2025.
◻ Value Added Tax Act (VAT Act)
The approved wording of the VAT Act that resulted from a significant tax revision of currently valid wording due to the impact of consolidated package has been additionally modified as of 1 January 2025.
A taxable person will be obliged to register for VAT purposes in Slovakia also if he fulfils the following conditions:
- supplies a building, part of a building or building land or supplies a building or part of a building exempt from VAT
- supplies goods within the territory of the European Union to a person other than the taxable person by means of an electronic communication interface (electronic marketplace, electronic platform, electronic portal or similar electronic means)
- acquires goods domestically from another EU Member State which are subject to VAT, if he already has a permanent establishment in Slovakia
The originally approved wording of VAT (apply from 1 January 2024) provided for exemption from the obligation to register for the supply of a building whose supply is exempt from VAT. Moreover, the condition of special tax treatment for distance sales of goods within the territory of the European Union, certain domestic supplies of goods and services supplied to persons other than taxable persons has been excluded.
Newly when goods or services are supplied, the tax base is determined by a new rule which determines the value of the tax base as follows:
- for the supply of goods, the purchase price of the goods at the time of supply shall be used (if this price cannot be ascertained, the purchase price of similar goods or the cost of creating such goods at the time of supply shall be used)
- the supply of a service is based on the cost of the service
Originally, the tax base was determined as the price at which the goods were purchased, including the costs related to the acquisition or creation by own activity or the residual value for depreciated assets.
Furthermore, the period when the VAT adjustment itself is made is specified for the correction and adjustment of the deducted tax on fixed investment assets as follows:
| Adjustment period | Defined fixed assets |
| 5 calendar years including the year in which the initial use of the investment asset took place | if it is a fixed asset: – movable items whose acquisition cost, excluding tax or cost price is EUR 3.319,39 or more and whose useful life is more than one year |
| 20 calendar years including the year in which the initial use of the investment asset took place | if it is a fixed asset: – buildings, building land, flats and non-residential premises – superstructures of buildings, extensions of buildings and building modifications of buildings, apartments and non-residential premises, which required a building permit under a special regulation |
Also, the rules on self-taxation on importation of goods (so-called samozdanenie pri dovoze tovaru in Slovak language) are adjusted to 30 June 2025.
◻ Electronic cash register Act (ERP Act)
Penalties for various tax offences (non-compliance) when using electronic cash registers are also amended. Please find below brief overview of the significant increase in penalties from 1 January 2025:
| Non-compliance | Original sanction | New sanction |
| Improper use, interference or circumvention of the ERP and failure to issue a receipt | EUR 330 – 3.000 | EUR 500 – 15.000 |
| Failure to record deposits and other facts in the ERP, to carry out mandatory maintenance and control or to maintain the ERP ledger | EUR 100 – 3.300 | EUR 150 – 6.500 |
| Failure to label goods and services in accordance with statutory conditions | EUR 20 – 100 | EUR 30 – 200 |
| Failure to indicate where sales are not accepted via ERP | EUR 50 – 330 | EUR 80 – 650 |
| Illegally alter the content, scope of information or tamper with the documents and functionality of the ERP | EUR 2.000 – 10.000 | EUR 3.000 – 15.000 |
| Violates the prohibition to sell goods at the point of sale | EUR 2.000 – 40.000 | EUR 3.000 – 60.000 |
The current rates of penalties for repeated infringements of the above administrative offences are changed. However, for administrative offences committed before the end of 2024, the original level of penalties will be applied.
◻ Trade Licensing Act
The year-end amendment package also involved the status and authorization of sole traders to carry out business. This law is supplemented by obstacles to the operation of certain trades by legal persons:
- trade license to carry out the mediation of sale, lease and purchase of real estate (real estate activities) and bookkeeping cannot operate a legal person, if its beneficial owner is not impeccable
This amendment is related to the update of the Law on the Protection against the Legalization of the Proceeds from Crime, in particular the provisions defining the final beneficiary. Following this change, companies have to adjust their legal relations with the final beneficiaries by 15 April 2025.
In addition, wording is added to the Trade Licensing Act that eases the administrative burden on entrepreneurs of submitting information that they have already provided to other state authorities. This information will be provided electronically by the institutions without the presence of the entrepreneur.
◻ Customs Act
Similar to other administrative charges, a several customer offences rates under the Customs Acts have been amended. Below are the changes adopted in customs fines or penalties:
| Offence | Original fine | New fine |
| A fine may be imposed for any customs offence depending on the seriousness of the breach of customs regulations | EUR 3.319,39 | EUR 10.000 |
| Penalty in the order procedure | EUR 1.659,68 | EUR 5.000 |
| Fine in block proceedings | EUR 331,93 | EUR 1.000 |
| Impose a fine for the customs offence of failing to declare accompanied cash or importing / exporting rough diamonds | EUR 33.193,91 | EUR 35.000 |
| Of which in order proceedings | EUR 17.500 | |
| Of which in block proceedings | EUR 5.000 | |
◻ Implementation of international sanctions Act
The Implementation of international sanctions Act is also regulated, where the roles of civil servants in the performance of tasks according to their competence are supplemented. These tasks include:
- coordinating the implementation of international sanctions within the framework of competences
- providing assistance to other staff of public authorities in the management of sanctions
- to control the fulfilment and obligations laid down by law and to impose measures to remedy deficiencies
- cooperate with other states in the enforcement of international sanctions
- to consider the criteria for the inclusion of persons on the sanctions lists and the removal of persons from the sanctions lists
- to decide whether to grant exemptions from the sanction’s regime
- make notifications to the relevant international and European Union databases related to the implementation of international sanctions
Simultaneously, the conditions under which a derogation from the sanction’s regime is allowed are also set out for taxpayers.
◻ Financial Administration Act
The amendment to the Financial Administration Act supplements the rights of the financial administration to control the transfer of cash at common borders with other Member States, including the provision of information on the purpose of the transfer of cash above the set limit – EUR 10.000.
In case the cash exceeds the specified limit when crossing the borders, the employee of the Financial Directorate can ascertain the following information:
- how much cash is transferred across the border
- information on the owner of the cash (identification details and address)
- the name of the owner of the cash if it is a legal person including identification details
- who is the recipient of the cash including identification details
- the origin of the cash to be transferred and the intended use of the cash abroad
If any person who carries (or surreptitiously carries) cash in excess of EUR 10.000 and conceals any information or amount of cash – the employee of Financial Directorate is entitled to seize all the cash found regardless of the objections of the person concerned.
Violations of the terms of the Act may result in the following offences:
| Offence | Amount of the fine | Basis for determining the fine |
| fails to declare the transport of cash in excess of EUR 10.000 or misrepresents the correct amount of cash | a fine of up to 10 % in direct proceedings | from cash in transit |
| a fine of up to 7 % in the order | ||
| a fine of up to 5 % in block |
These changes shall take effect from 15 January 2025.
